Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Discount to the customer - disproportionately higher percentage - merely because there was variations in the previous and subsequent year with regard to the discount and rebates, AO should not have disallowed the claim of the appellant with regard to the discount and rebates and profits.
Discount to the customer - disproportionately higher percentage - merely because there was variations in the previous and subsequent year with regard to the discount and rebates, AO should not have disallowed the claim of the appellant with regard to the discount and rebates and profits.
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